US EPA Announces New Landfill Emissions Rules

On July 15, 2016 the United States Environmental Protection Agency (EPA) announced a new final rule limiting greenhouse gas and other emissions from newly constructed municipal solid waste landfills, together with emissions guidelines for existing landfills. EPA estimates that the new standards, will cover over 1,100 new and existing facilities at a combined compliance cost of approximately $60 million by 2025.

The new standards apply to landfills that have design capacities of 2.5 million metric tons and 2.5 million cubic meters or more of waste, the same applicability threshold as the current rules promulgated in 1996. The limitations for new facilities, under Section 111(b) of the Clean Air Act (New Source Performance Standards or NSPS), cover facilities that were built or modified after July 17, 2014. The emissions guidelines are for existing facilities built before that date. The NSPS apply directly to individual facilities, while the emissions guidelines are implemented by states via state-specific plans.

Under both the rule and the guidelines, facilities that meet the design thresholds and emit over 34 metric tons of non-methane organic compounds (NMOC) per year will be required to install gas collection control systems (GCCS). Acceptable systems include enclosed combustion for energy generation, treatment for sale or beneficial use, and flaring. If a landfill can demonstrate that surface NMOC emissions are below 500 parts per million for consecutive quarters, it may be exempt from the GCCS requirements even if it meets the applicability thresholds.

The rule and the guidelines will take effect 60 days after their publication in the Federal Register. Any facility that meets the design capacity threshold will have 30 months to install GCCS after its NMOC emissions meet 34 metric tons per year. EPA anticipates that over 100 newly constructed or modified landfills and over 700 older facilities will need to install GCCS by 2025.